In The United States District Court
For the Southern District of Texas
Houston Division
Civil No. 4:10-CV-02220
Louis Charles Hamilton II
Plaintiff Motion to Compel
Vs.
Samuel Benjamin Magnus-Lawson, M.D., (dob.) 8/11/1964 a/k/a Rex Okusaga (DOB.)10/04/48 a/k/a Prince Benjamin Magnus-Lawson of Lagos Nigeria, Africa a/k/a Ben Magnus-Lawson (dob.)11/12/1961
St. Joseph Medical Center, et al
D. Bret Edwards (ESQ.)
Johanna Ann Magnus-Lawson
Jane and John Doe (ESQ.)
Collectively Defendant(s)
Comes now the Pro Se Plaintiff Louis Charles Hamilton II moves the above Honorable Court for Order to compel defendant(s): Samuel Benjamin Magnus-Lawson, M.D., in the production of the documents through his Attorney of record Mr. Olu McGuinnis Otubuis to produce to the Plaintiff all “discovery sought” as outline in paragraph (1-66) in the Plaintiff exhibit (A) attached herein
With “certificate of mailing services” in support of mailing service attached as Plaintiff exhibit (B) was executed in accordance with the civil rules of the above entitled Honorable U.S. District Court
To include but not limited to the Defendant (Lawson M.D.) having further failure to respond to Plaintiff “original motion for disclosure” in accordance with Fed. R. Civ. P. 26(a)(1) request attached as Plaintiff exhibit (C) which Plaintiff further seeks Order for said disclosure being produce and address also.
For cause the Plaintiff will show as follows:
1. The Plaintiff having served the name address defendant and attorney of record Mr. Olu McGuinnis Otubuis in a timely fashion as exhibit (B) clearly indicates.
2. The discovery sought is very accurate, as it should be, correct and is in complete factual scope to this action as describing the defendant(s) conduct, events, circumstances, timeline, incidents, records and documents need for a complete understand of putting this matter before a Honorable Court to render a fair Judgment;
3. All of which the Plaintiff discovery request at this time coincide with the “allegations raised” against primary defendant (Lawson M.D.) with some evidence referring to the other Co-Defendant(s) to this action.
4. Plaintiff position at this time of already having filing “damaging evidence” against the Defendant(s) by way of current exhibits on file in regards to fictitious records, different bogus identifications of (Lawson M.D.) and deposition in support among other present exhibits in support of the Plaintiff position.
5. Plaintiff Medical documentations evidence & exhibits supports the Plaintiff position throughout this action from the “very start” and easily able to satisfy the Honorable Court and Jury in regards to “actual physical evidences” the defendants having engaged in the numerous “illegal, fanatical and extreme, bizarre, wrongful conduct(s) as described throughout all the records here within.
6. The defendant (Lawson M.D.) through his attorney of record wishes to cause undue, unjust and unwanted delays in light of the circumstances the Plaintiff presented in regards to (Johanna) needed (ASAP) Professional medical attention to be restored to the normal condition she was once maintaining and enjoyed with out the corrupt doctoral interference of Lawson M.D. for fraudulent means.
7. The Plaintiff wish to fast track this matter before the Honorable Court in ever aspect and Plaintiff having the good common sense, moral support, and a stock pile of evidence, facts, and bizzars circumstances the defendants will need several dump trucks of attorneys to explain these indiscretions, impropriety, misdeeds, impudence, peccadillo and indelicacy of all which was committed in violation(s) under (RICO) statue;
8. To include but not limited to defendant (Lawson M.D.) need several dump trucks of Attorneys to explain/white wash, these bizarre list(s) of actual circumstances, indiscretions, impropriety, misdeeds, impudence, peccadillo and indelicacy of all which was committed in violation(s) against Namely the United States Oath of Allegiance (officially referred to as the "Oath of Allegiance," 8 C.F.R. Part 337 (2008).
Conclusion
The contention that an injury can amount to a crime only when inflicted by intention is no provincial or transient notion. It is as universal and persistent in mature systems of law as belief in freedom of the human will and a consequent ability and duty of the normal individual to choose between good and evil.
A relation between some mental elements and punishment for a harmful act is almost as instinctive as the child’s familiar exculpatory “But I didn’t mean to,” and has afforded the rational basis for a tardy and unfinished substitution of deterrence and reformation in place of retaliation and vengeance as the motivation for public prosecution.
Unqualified acceptance of this doctrine by English common law in the Eighteenth Century was indicated by Blackstone’s sweeping statement that to constitute any crime there must first be a “vicious will”.
Robert H. Jackson, Morissette v. United States, 342 U.S. 246, 250-51 (1952).
Wherefore the Pro Se Plaintiff Louis Charles Hamilton II moves the Honorable Court to order the defendant (Lawson M.D.) to “comply and produce” the entire discovery request(s) to the Plaintiff in full, complete, as each request has been set and outline in exhibit (A) paragraph 1-66
To include the Plaintiff moves the Honorable Court that the defendant(s) comply and supply some sort of respond to Plaintiff “original motion for disclosure” in accordance with Fed. R. Civ. P. 26(a) (1) request attached here within as Plaintiff exhibit (C).
And for any other reasoning this Honorable U.S. District Court in and For the Southern District of Texas, Houston Division, Deems Just Honorable and proper on the behalf of the Pro Se Plaintiff Louis Charles Hamilton II.
Dated On the _______ Day of __________, 2010
By, ____________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 20126
Houston Texas 77225
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